Investment Research Associates - Page 456




                                       - 505 -                                         
          In addition, respondent argues that the testimony of Mallin and              
          Uhl is suspect and not credible.                                             
               We agree with respondent.  At the outset we observe,                    
          contrary to certain facts alleged by IRA, that this record                   
          clearly establishes that IRA was engaged in the practice of                  
          purchasing tax benefits, rather than buying and leasing computer             
          equipment for economic, profit-oriented reasons.                             
               To fully appreciate IRA's tax motivation for entering into              
          these leasing transactions, we have considered them in the                   
          context of the schemes and other issues raised in these                      
          consolidated cases.  There is no doubt that IRA was a vital cog              
          in Kanter's sophisticated financial machinations.  IRA, Holding              
          Co., the "black box" represented by Administration Co. and                   
          Principal Services, and the other various investment entities                
          created as alter egos of Kanter, constituted devices by which                
          Kanter received and disguised fees for his personal services,                
          including moneys received pursuant to the Prudential scheme.                 
          When these matters are viewed in context, we are persuaded that              
          the leasing transactions were consummated for the sole purpose of            
          producing deductions sufficient to offset the income reported on             
          IRA's Federal income tax returns.  Furthermore, to ensure that no            
          net income would have to be reported by IRA, all of the equipment            
          was effectively disposed of after the tax benefits were fully                
          utilized.                                                                    






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